Effective Date: July 31, 2026

Owned and Operated by: HPB Realty Private Limited ("Company", "We", "Us", "Our")

Platform: hotpropertybazaar.com ("Website", "Platform", "Mobile Applications - iOS & Android")

1. Introduction & Statutory Compliance

This Cookie Policy explains how HPB Realty Private Limited uses cookies, web beacons, tracking pixels, and similar tracking technologies when you visit our Platform. In strict compliance with the Information Technology Act, 2000, the Digital Personal Data Protection Act (DPDPA), 2023, and the DPDP Rules, 2025, this policy provides clear, transparent, and unconditional notice regarding data processing.

By using our Platform, you acknowledge that you have read, understood, and consented to the use of cookies as described herein. In alignment with the DPDP framework, you remain the "Data Principal" and HPB Realty Private Limited acts as the "Data Fiduciary".

2. What are Cookies?

Cookies are small text files placed on your device (computer, smartphone, or tablet) by websites you visit. They are widely used to make websites work efficiently, improve user experience, and provide analytical data to website owners.

Under Indian law, when a cookie stores identifiers (such as IP addresses, unique device IDs, or user preferences) that can directly or indirectly identify you, that data is treated as Digital Personal Data and protected accordingly.

3. Types of Cookies We Use

To protect HPB Realty Private Limited’s operational metrics while respecting public transparency, we classify our cookies into the following categories:

A. Strictly Necessary Cookies (Essential)

These cookies are foundational to the operation of hotpropertybazaar.com. They enable core functionalities such as secure user log-ins, real-estate property sorting, search filters, and session maintenance.

• Legal Basis: Under the DPDP Act, these are vital for fulfilling a service explicitly requested by you (accessing and navigating the site).
• Business Protection: These cookies cannot be disabled via our standard cookie preference center, as doing so would compromise website security and operational stability.

B. Performance and Analytics Cookies

These cookies collect aggregated information on how visitors interact with our Platform (e.g., which property listings are viewed most frequently, page load errors, and traffic sources).

• Tools Used: May include Google Analytics or similar corporate web-traffic measurement utilities.
• Legal Basis & Protection: Explicit, opt-in consent. Data collected via these cookies is anonymized or pseudonymized wherever possible to protect public privacy while retaining necessary business insights for the Company.

C. Functionality Cookies

These allow our Platform to remember choices you make (such as your preferred language, city/region preferences for property searches, or saved properties) to provide a personalized experience.

• Legal Basis: Explicit, opt-in consent.

D. Targeting and Advertising Cookies

These tracking technologies monitor your browsing habits across hotpropertybazaar.com and third-party websites to build a profile of your interests and display targeted real estate advertisements.

• Strict Government Compliance (Minors): In strict accordance with Section 9 of the DPDPA, 2023, HPB Realty Private Limited does not engage in behavioral tracking, targeted advertising, or profiling directed at minors (individuals under 18 years of age).
• Legal Basis: Explicit, opt-in consent.

4. How Third-Party Cookies Are Handled

The Platform integrates trusted third-party services (such as property map locators, virtual tour plugins, and social media sharing buttons). These third parties may set their own cookies on your device.

• Liability Disclaimer: The Company does not exercise direct control over the data lifecycle or cookie policies of independent third-party fiduciaries. We accept no liability for third-party cookie operations. Users are advised to review the respective privacy policies of those third-party providers.

5. DPDP-Compliant Consent & Control Mechanism

In adherence to the opt-in model mandated by the Indian Government, no non-essential cookies (Analytics, Functional, Advertising) will be deployed on your device until you provide clear, affirmative action via our Cookie Consent Banner.

Managing Preferences:

1.      Cookie Banner: Upon your first visit (or periodically upon cookie expiry), a clear, unambiguous prompt will allow you to "Accept All", "Reject All" (non-essential), or customize preferences.

2.      Browser Controls: You can restrict, block, or delete cookies through your web browser settings (e.g., Chrome, Safari, Edge, Firefox).

3.      Right to Withdraw: Under Indian law, you have the right to withdraw your consent to tracking at any time. A link to adjust your cookie preferences is permanently available in our website footer. Withdrawal of consent will not affect the lawfulness of processing based on consent prior to its withdrawal.

6. Due Diligence: Duties of the Public (Data Principals)

While the Company strictly protects user privacy, the DPDPA, 2023 (Section 15) outlines enforceable statutory duties for the public.

• When interacting with hotpropertybazaar.com, you are legally obligated not to suppress material information, impersonate other individuals, or lodge false or frivolous privacy/cookie grievances.
• The Indian Government empowers the Data Protection Board (DPB) to penalize individuals (up to ₹10,000) who violate these basic duties.

7. Real-Time Geo-Location Tracking via Cookies

As a property portal, hotpropertybazaar.com utilizes geographical tracking technologies (including IP-based location and GPS triangulation via browser-level APIs) to recommend local property listings, structural trends, and real estate updates close to your current physical position.

• Voluntary Disclosure: This location tracking occurs exclusively upon your explicit browser-level prompt allowing location access.
• Business Shield: If you deny location access, our Platform will fall back to a default location (e.g., National Capital Region or state capitals). The Company accepts no liability for generalized, less accurate property suggestions resulting from user-restricted location tracking.

8. Data Retention & Automatic Purging Timelines

In strict adherence to the data minimization mandates enforced by the DPDPA, 2023, HPB Realty Private Limited does not hold cookie-derived digital personal data indefinitely.

• Session Data: Automatically flushed the moment you close your web browser.
• Persistent Analytics & Preferences: Retained for a maximum structural period of twelve (12) months from your last active session, after which the data is automatically overwritten, anonymized, or deleted.
• Overriding Clause: We reserve the right to retain anonymized analytical metrics indefinitely, as they no longer fall under the definition of "Digital Personal Data" under Indian law and are critical for evaluating business growth, platform health, and server scaling.

9. Cross-Border Data Transfers & Server Cloud Safeguards

To maintain high uptime and page speeds, HPB Realty Private Limited utilizes localized Content Delivery Networks (CDNs) and cloud servers.

• Public Due Diligence: While the backend database strictly complies with the localization directives of the Government of India, certain cross-border caching of anonymous cookie logs may happen securely across encrypted globally distributed nodes.
• Business Protection: By accepting our Performance cookies, you explicitly acknowledge that these routing configurations do not constitute a violation of your privacy rights, provided that the target countries have not been blacklisted by the Ministry of Electronics and Information Technology (MeitY).

10. Digital Consent Architecture & Consent Managers

Under Section 6 of the DPDPA, 2023, the Indian government introduces an institutional framework allowing Data Principals to give, manage, or withdraw consent through a designated "Consent Manager."

• HPB Realty Private Limited fully supports integrations with interoperable, government-registered Consent Managers as soon as they are technically deployed via the official digital portals.
• Until such frameworks are accessible to the public, our native cookie preference dashboard operates as the official primary apparatus for managing all tracking mandates.

11. Severe Prohibitions against Scraping & Automated Interception

• Intellectual Property Protection: All cookies, tokens, and session identifiers generated by hotpropertybazaar.com are the exclusive intellectual property of the Company.
• Legal Action Matrix: Any attempt by competitor aggregators, data scrapers, bots, or unauthorized scripts to intercept session cookies, reverse-engineer user search behaviors, or extract property catalog metadata using artificial sessions will be viewed as a malicious cyber-attack. The Company will aggressively prosecute such acts under Sections 43 and 66 of the Information Technology Act, 2000 along with applicable penal provisions under the Bharatiya Nyaya Sanhita (BNS), 2023.

12. Limitation of Liability & Indemnity (Business Protection)

To the maximum extent permitted under applicable Indian laws, HPB Realty Private Limited, its directors, employees, and affiliates shall not be held liable for any indirect, incidental, special, or consequential damages resulting from:

• Unauthorized third-party access to cookie data despite the implementation of industry-standard security safeguards.
• Disruption of website functionality if you choose to reject or block strictly necessary cookies.
• User errors in managing browser-level tracking or device settings.

13. Severability and Jurisdiction

• Severability: If any individual provision within this Cookie Policy is determined to be invalid, unlawful, or unenforceable by the Data Protection Board of India (DPBI) or an Indian Court of competent jurisdiction, that specific clause will be struck down cleanly without affecting the statutory legality, validity, and absolute enforceability of the remaining portions of this policy.
• Governing Law & Jurisdiction: This Cookie Policy shall be governed by and construed in accordance with the laws of India. All disputes, structural investigations, or legal actions regarding this tracking setup, platform data processing, or cookie deployment shall fall exclusively under the judicial jurisdiction of the competent courts located in the city or state where the Registered Office of HPB Realty Private Limited (or its parent corporate entity) is situated at the time of the dispute. The user/visitor explicitly waives any objection to such jurisdiction or venue.

14. Updates to this Policy

HPB Realty Private Limited reserves the right to modify, amend, or alter this Cookie Policy at any time to reflect changing technological trends, operational requirements, or legislative updates directed by the Ministry of Electronics and Information Technology (MeitY) or the Data Protection Board of India. Any changes will become effective immediately upon being posted on the website.

15. Grievance Redressal Officer (DPDPA Compliant)

In accordance with the mandates of the Government of India, if you have any questions, concerns, complaints, or wish to exercise your data principal rights regarding cookies and tracking data, you may contact our designated Grievance Officer:

• Attn: Grievance Redressal Officer / Data Protection Officer
• Company Name: HPB Realty Private Limited
• Email Address: [Insert dedicated email, e.g., privacy@hotpropertybazaar.com]
• Mailing Address: [Insert physical registered/corporate office address in India]

We commit to acknowledging and addressing all legitimate grievances within the statutory timelines prescribed under the DPDP Rules.